Cited by
Opinions in Minnesota that cite Andersen v. State, 830 N.W.2d 1.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Appellate courts “generally do not review a n ineffective-assistance-of-counsel claim that is based on trial strategy.” Andersen v. State , .
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Under the first prong, “there is a strong presumption that counsel’s performance was reasonable.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Under the two-prong Strickland test, a defendant must show that (1) “counsel’s performance fell below an objective standard of reasonableness, and (2) that a reasonable probability exists that the outcome would have been different but for counsel’s errors.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
(“Generally, an ineffective assistance of counsel claim should be raised in a postconviction petition for relief, rather than on direct appeal.”).
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Derrick Lemar Forest, petitioner, Appellant,
Minn. Ct. App. 2024
There is a “strong presumption that counsel’s performance was reasonable.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
But where “a claim of ineffective assistance of trial counsel can be determined on the basis of the trial record, the claim must be brought on direct appeal.”
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Chad Alan Hoflock, petitioner, Appellant,
Minn. Ct. App. 2024
“[T]here is a strong presumption that counsel’s performance was reasonable.”
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Isaac Alonzo Cryer, petitioner, Appellant,
Minn. Ct. App. 2024
When applying the first prong of Strickland, “there is a strong presumption that counsel ’s performance was reasonable.” .
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
But “[w]hen a claim of ineffective assistance of trial counsel can be determined on the basis of the trial record, the claim must be brought on direct appeal.”
- Duke Ogeto Maroko, petitioner, Appellant, Minn. Ct. App. 2024
- State of Minnesota, Respondent, Minn. Ct. App. 2024
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
“[T]here is a strong presumption that counsel’s performance was reasonable.”
- State of Minnesota, Respondent, Minn. Ct. App. 2024
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Alexander John Cookson, petitioner, Appellant,
Minn. Ct. App. 2024
Strickland test, we nevertheless conclude that the district court did not abuse its discretion in denying postconviction relief because Cookson has not satisfied Strickland’s prejudice prong.6 5 “When a claim of ineffective assistance of trial counsel can be determined on the basis of the trial record, the claim must be brought on direct appeal or it is Knaffla-barred.”
- Arthur Rafie Mullins v. State of Minnesota Minn. Ct. App. 2024
- State of Minnesota v. Rosalio Martinez, Jr. Minn. Ct. App. 2024
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State of Minnesota v. Rosalio Martinez, Jr.
Minn. Ct. App. 2024
(citing Crawford v. Washington, 541 U.S. 36, 59 (2004)).
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Arthur Rafie Mullins v. State of Minnesota
Minn. Ct. App. 2024
“that took place between the plea and sentencing hearing.” A claim for ineffective assistance of trial counsel is not procedurally barred “when the claim requires examination of evidence outside the trial record or additional fact-finding by the postconviction court, because the claim is not based solely on the briefs and trial court transcript.” see, (stating that defendant’s claim that “his trial counsel failed to communicate two plea offers requires additional factfinding, so it is not barred
- State of Minnesota v. Angel Ignacio Sardina-Padilla 7 N.W.3d 585 Minn. 2024
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State of Minnesota v. Angel Ignacio Sardina-Padilla
7 N.W.3d 585
Minn. 2024
Under the Strickland test, the appellant must show (1) that “his counsel’s performance fell below an objective standard of reasonableness, and (2) that a reasonable probability exists that the outcome would have been different but for counsel’s errors.”
- State of Minnesota v. Michael Adam Davis Minn. Ct. App. 2024
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State of Minnesota v. Michael Adam Davis
Minn. Ct. App. 2024
6 This court will not second guess the trial-strategy decision of which 6 See, (noting that decision to call exculpatory witnesses falls within trial strategy and is not reviewable on appeal); -27 (Minn. 1992) (determining that trial counsel’s failure to call three potential witnesses was within counsel’s trial strategy).
- State of Minnesota v. Marvel Galvaston Williams Minn. Ct. App. 2024
- State of Minnesota v. Marvel Galvaston Williams Minn. Ct. App. 2024
- Fidele Ndaruhutse v. State of Minnesota Minn. Ct. App. 2024
- State of Minnesota v. Mickela Joy Vredenburg Minn. Ct. App. 2024
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State of Minnesota v. Mickela Joy Vredenburg
Minn. Ct. App. 2024
does not bar the use of testimonial statements for purposes other than establishing the truth of the matter asserted.” Crawford, 541 U.S. at 59 n.9
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Fidele Ndaruhutse v. State of Minnesota
Minn. Ct. App. 2024
And “there is a strong presumption that counsel’s performance was reasonable.”
- State of Minnesota v. Daryl Shannon Williams Minn. Ct. App. 2024
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State of Minnesota v. Daryl Shannon Williams
Minn. Ct. App. 2024
(state bears the burden of proving that a statement is not testimonial); (state bears the burden of proving that defendant’s Sixth Amendment rights were not violated); (state bears the burden of establ
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Anderson v. State , (citing Crawford v. Washington, 541 U.S. 36, 59 (2004)).
- State of Minnesota v. Jeffrey Velt Murray Minn. Ct. App. 2024
- State of Minnesota v. Damarcus Deontay Holloway Minn. Ct. App. 2024
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State of Minnesota v. Damarcus Deontay Holloway
Minn. Ct. App. 2024
(citing Crawford, 541 U.S. at 59 & n.9).
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State of Minnesota v. Jeffrey Velt Murray
Minn. Ct. App. 2024
Under Strickland, a defendant “must demonstrate that (1) his counsel’s performance fell below an objective standard of reasonableness, and (2) that a reasonable probability exists that the outcome would have been different but for counsel’s errors.”
- State of Minnesota v. Ronald Lee Schober Minn. Ct. App. 2024
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State of Minnesota v. Ronald Lee Schober
Minn. Ct. App. 2024
(noting that counsel’s alleged conduct—including that he was unprepared at trial, did not read the discovery, failed to investigate the case, and did not call exculpatory witnesses—“arguably falls within trial strategy and therefore is not reviewable”).
- State of Minnesota v. Carmen Marie Burth Minn. Ct. App. 2023
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State of Minnesota v. Carmen Marie Burth
Minn. Ct. App. 2023
(citing Crawford 7 v. Washington, 541 U.S. 36, 59 & n.9 (2004)).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
- State of Minnesota v. Jack Guy Minn. Ct. App. 2023
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State of Minnesota v. Jack Guy
Minn. Ct. App. 2023
Admission of an out-of-court statement violates the Confrontation Clause when “the statement in question was testimonial, the statement was admitted for the truth of the matter asserted, and the defendant was unable to cross-examine the declarant.” (citing Crawford v. Washington, 541 U.S. 36, 59 & n.9 (2004)).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
(“We give trial counsel wide latitude to determine the best strategy for the client.”).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
See Andersen v. State , (explaining that appellate courts generally will not review an ineffective-assistance-of-counsel claim that is based on trial strategy, which “includes the selection of evidence presented to the jury”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
d 493, 506 (Minn. 2013) (“We give trial counsel wide latitude to determine the best strategy for the client.”).
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Carlos Kendall Duncan, petitioner, Appellant,
Minn. Ct. App. 2023
(noting that the decision to call exculpatory witnesses falls within trial strategy and is not reviewable on appeal) ; (stating that strategic trial decisions include “what evidence to present to the jury, what witnesses to call, and whether to
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Sophia Wang Navas, petitioner, Appellant,
Minn. Ct. App. 2023
“We need not address both the performance and prejudice prongs if one is dispositive.”
- Stephen Carl Allwine, Minn. 2023